Robert E Culbertson
USA Guide 2023
Band 3 : Tax
Email address
[email protected]Contact number
+1 202 662 5004Share profile
Band 3
About
Provided by Robert E Culbertson
Practice Areas
International tax planning and controversy resolution, focusing on foreign tax credit, GILTI, and inbound investment issues. Advises on structural and transactional tax planning; handles IRS audits, appeals, and rulings; represents clients in regulatory and legislative processes.
Career
30 plus years international tax experience. Served as IRS Associate Chief Counsel International, where significant projects included regulations on foreign tax credits, subpart F, outbound transfers, and conduits, as well as revision of transfer pricing regulations and OECD guidelines. Joint Committee on Taxation staffer during 1986 Tax Reform Act.
Personal
Cum laude graduate of Yale University and Harvard Law School.
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Covington & Burling LLP
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